Last update: 31.03.2023

This privacy statement is designed to fully inform you about our privacy practices including the collection of personal data, how we use it and the rights that exist for you to fully be in control of it. We love to interact with our customers so that we can learn and continue to improve the services we offer to the HRC Academy community, which means data is exchanged and used on many occasions including when you use website forms or visit our academy.

2. Who we are

This Privacy Statement applies to the processing of personal data by HRC Academy and more specifically the relevant subsidiary that determines the particular purpose of the personal data that is processed. In practice, the data controller will be HRC Academy.

HRC Academy is a limited liability company registered under the laws of Bulgaria with its statutory seat in Sofia, Bulgaria, and its office at 59, Tsar Boris III, Blvd registered with the Bulgarian Chamber of Commerce under Company ID: 124707063.

3. Changes

We may change this Privacy Statement to reflect changes at any time. The most recent version of the Privacy Statement is reflected by the version date located in the top left of this document. All updates and amendments are effective immediately upon notice, which we may give by posting a revised version of this Privacy Statement on the Website. We encourage you to review this Privacy Statement often to stay informed of changes that may affect you, as your continued use of our services signifies your continuing awareness of this Privacy Statement.

4. What personal data do we collect and why?

The type of data that HRC Academy collects and what we do with it depends on how it was collected and the type of service you have signed up to enjoy. For example:

If you visit the HRC Academy website, we use cookies, which we store on your computer, phone or tablet. Cookies are small text files, and we use the information contained in these files for the essential functioning of our sites, non-essential functions to improve user experience, performance/analytics and advertising.

To a large extent cookies concern anonymized data to help us analyze how users use the websites so that HRC Academy can improve the functionality and the content.

We may use this information for additional purposes depending on the cookie preferences you select in the cookie setting banner, for example, to provide relevant offers on other websites you visit via online and third-party advertisements. We may also use this information for remarketing purposes to remind and assist you with potential applications that were left incomplete.

Subscribing using forms (online and offline)
When you subscribe to a newsletter, event, or deal, online or offline you will be requested to provide certain data, which may include name, e-mail, the event you’re interested in, residence, city, gender, phone or/and date of birth or/and product preferences.

We use this information to contact you about the relevant topic you have indicated you are interested in. We will only contact you when we believe there is a legitimate interest to do so based on the interest and information you have declared.

We may also use this information to send general marketing e-mails about other HRC Academy news, events and deals but only if you have given us consent to do so by clicking the opt-in tick-box when making the booking. You can unsubscribe from marketing e-mails at any time by clicking the unsubscribe link contained in the e-mail.

After your HRC Academy experience
After what we hope is only your first HRC Academy experience we will continue to store your personal data in a profile that is strictly accessible only by HRC Academy. Should you return to HRC Academy in the future, we want to be able to offer the best possible service, including the ability to customize your stay based on your previous personal preferences. We will only do this to the extent that we believe we have a legitimate interest to do so which in every case will be to improve the service we can offer to you in the future across all our locations and services.

The data collected may therefore be kept for as long as we believe you may return to HRC Academy or until you communicate your right to be deleted.

We will also continue to send you marketing e-mails to keep you updated if you have previously given consent for us to do so and will continue to do so for as long as we believe the content is valid and of interest to you.

You can of course unsubscribe anytime you like by following the link contained at the bottom of the email or contacting  info@hrcacademy.com

5. Legal grounds for the processing activities identified

Based on the contractual agreement

• To manage your application through any of the channels provided to this effect and to process your registration as an HRC Academy customer and for the subsequent business relations with you.
• Managing, maintaining and effectively controlling the relationship resulting from having contracted the HRC Academy goods or services.

Based on legal obligations

• Notify the public authorities or regulatory or government bodies in those cases where it is necessary to do so under law, local by-laws or in compliance with regulatory requirements.

Based on HRC Academy legitimate interests

• Carry out commercial actions and/or advertising communications through any medium including electronic or equivalent communications relating to goods or services offered by HRC Academy.
• Create profiles based on the personal data available to HRC Academy to ascertain the goods and services most appropriate to your profile, thus maximizing their results and in this way offering you the best of any goods and services of interest to you.
• To carry out customer satisfaction surveys with the goods and/or services you have contracted to assess your satisfaction so that HRC Academy can improve its processes and services.
  To manage, process and respond to any possible complaints or claims. It is in the HRC Academy’s legitimate interests to maintain the quality of its service and to use the recordings, should it be necessary to protect its legal position in the event of any possible conflict.
• To send operational relevant information about the HRC Academy product you have purchased or the event you have attended.
• To assess what students or employees have entered into an HRC Academy service agreement as a consequence of a partnership agreement between HRC Academy and an educational or corporate partner.

Based on your explicit consent

• Should you so authorize (typically using an opt-in tick box), HRC Academy may send marketing material about goods and services other than those that you have contracted or subscribed to. HRC Academy may contact you about relevant goods and services after a contractual relationship has ended.
• Should you so authorize on the cookies banner, HRC Academy may monitor cookies and use that information to advertise products/services that may be of interest to you.
• Should you give consent for HRC Academy to process your data in a different way that is explained at the time of receiving your consent.

6. Who has access to your personal data?

We handle your personal data discretely and access is strictly limited to HRC Academy and our third-party partners who have a need to know such information to effectively fulfil our contractual obligations towards you when it is necessary to perform functions you have granted consent for us to do or any other identified legal ground under data protection law such as an identified legitimate interest. For example, if you subscribe to an HRC Academy service your data will be stored in a third-party CRM which will help us optimize your guest journey as much as possible.

7. Your rights

We want to make sure that you are fully in control of your personal data. You have multiple rights and we want to ensure they are respected. If you wish to exercise any of the rights listed below, please make your request by sending an e-mail from the email address that you used when signing up for an HRC Academy service to info@hrcacademy.com

Please state clearly in the subject heading what type of request you are making including as much detail as you can to assist us to complete your request as quickly as possible. Please confirm as a minimum:

• Type of HRC Academy service you signed up for
• Dates
• Supporting evidence to help identify the correct profile
• We will complete your request within 4 weeks.

Right of access
If you want to know what personal data we have collected and/or processed from you, you can request HRC Academy to provide an overview. We will provide you with an overview of the personal data that we collect and/or process.

Rectification
If you believe that the personal data that we process is incorrect, inaccurate or incomplete, you may ask us to change or remove such personal data.

Erasure
If you want us to remove the personal data we have collected and/or processed from you, you can request HRC Academy to erase your personal data.

Restriction
Instead of requesting erasure, you may also request us to restrict the way we are processing your personal data if this right to restriction does not conflict with a processing activity that is required for the performance of the contract, required by law and does not outweigh a HRC Academy legitimate interest.

Portability
If you want to transfer the processed personal data to another controller of your choice, you may request us to provide you with a copy of your personal data in a structured, commonly used, and machine-readable format.

Object
You have always the right to object to the processing of your personal data by HRC Academy. If it concerns a processing activity that requires consent you are always entitled to remove your consent.

Limitations of your rights
When a data subject request is made HRC Academy will as a standard policy provide this service free of charge, however in exceptional cases HRC Academy reserves the right to charge a reasonable fee. Data subject requests will only be implemented after the individual making the request has proved their identity, which confirms that they are indeed the subject that the request concerns. This can be achieved by sending the request from the same email address that was used when signing up for an HRC Academy service.

Finally, in certain situations, HRC Academy may be entitled to legally refuse requests. If HRC Academy believes there are legitimate grounds that override the interest of the data subjects’ request, then HRC Academy may reasonably refuse to fulfil the request. HRC Academy will always justify in writing why that is the case.

Right to contact the supervisory body
If you believe your data request is not being handled correctly you are entitled to contact the HRC Academy lead national data supervisory body.

8. How do we protect your personal data?

HRC Academy takes the security of personal data seriously and has implemented the following security measures:

Physical Access Controls: HRC Academy has taken reasonable measures to prevent physical access, such as security personnel and secured buildings to prevent unauthorized persons from gaining access to Personal Data or has ensured third-party partners operating data centres on our behalf are adhering to such controls.

System Access Controls: HRC Academy has taken reasonable measures to prevent Personal Data from being used without authorization. The controls vary based on the nature of the processing undertaken and may include, among other controls, authentication via passwords and/or two-factor authentication, documented authorization processes and logging of access on several levels.

Data Access Controls: HRC Academy takes reasonable measures to ensure that Personal Data is accessible and manageable only by properly authorized staff; application access rights are established and enforced to ensure that persons entitled to use a system only have access to Personal Data to which they have the privilege of access and a companywide policy that Personal Data cannot be read, copied, modified or removed without authorization in the course of processing.

Transmission Controls: HRC Academy has taken reasonable measures to ensure that it is possible to check and establish to which entities the transfer of Personal Data by means of data transmission facilities is envisaged so Personal Data cannot be read, copied, modified or removed without authorization during electronic transmission or transport.

Input Controls: HRC Academy has taken reasonable measures to provide that it is possible to check and establish whether and by whom personal data has been entered, modified or removed from a system. HRC Academy has taken reasonable measures to ensure that (i) the Personal Data is always under HRC Academy’s control and (ii) Personal Data is managed by secured transmission.

Logical Separation: Data collected for different HRC Academy services and purposes is logically segregated separated systems to ensure that personal data that is collected and processed for the particular purpose it was collected for by HRC Academy.

9. Transfer of personal data to other countries

For many of our business purposes, we use cloud-based services. Therefore, for technical and organizational reasons, it may be necessary that your personal data be transferred to servers located in other countries outside of the European Economic Area. HRC Academy has implemented internal processes to ensure that your personal data will only be sent to parties and/or countries with an adequate level of personal data protection.

10. Links to other websites

The Websites may contain links to other websites we do not control. Therefore, we will not be responsible for the content of these websites, nor for the processing of personal data that may occur on these websites.

11. Questions

If you have any questions about this Privacy Statement, please email:

info@hrcacademy.com